As announced in August 2025, the IPA paused the enforcement of the two withhold limit, from Part I application submissions to the ICC meetings for REC Contract approval, due to the Federal Reconciliation Bill (H.R.1) and the Executive Order issued on July 7, 2025. The pause will be lifted for the July 16, 2026, ICC meeting, with the start of ICC submissions under the 2026-27 Program Year. After the start of the 2026-27 Program Year, DG projects will only be permitted to be withheld twice before they must be submitted to the ICC for REC Contract approval or permanently withdrawn from the Program. Projects that have been withheld more than two times already will be required to submit to the ICC or withdraw at the first ICC meeting submission after June 1, 2026. This process is further outlined in Section 5.A of the 2026-27 Program Guidebook.
